MEMORANDUM FOR Directors, Offices of Small and Disadvantaged Business Utilization

SUBJECT Subcontracting plan review under 15 U.S.C. § 644(k)

The mandate did not change.The capacity did.

PTOD-OS Federal reviews a contractor's small business subcontracting plan against every element the governing clause requires, element by element, and prepares a determination memorandum. It finds what is in the document. It does not decide what to do about it.

Determination

The subcontracting plan is ACCEPTED

The subcontracting plan is NOT ACCEPTED

Director, OSDBU

Date

This block appears on every memorandum the system produces. It is always blank. There is no automated approval path anywhere in the product.

What it reviews

Fifteen elements, each one checked and cited

The clause enumerates what a subcontracting plan must contain. Twelve of those elements are objective — a requirement is present in the document or it is not — and their status is computed by a written rule. Three call for judgment about whether a description is adequate, and those are referred to the Director rather than decided.

(d)(1)

Separate goals by socioeconomic category

(d)(2)

Total dollars planned to be subcontracted

(d)(3)

Principal types of supplies and services

(d)(4)

Method used to develop the goals

(d)(5)

Method used to identify potential sources

(d)(6)

Indirect costs statement and allocation

(d)(7)

Program administrator and duties

(d)(8)

Equitable opportunity efforts

(d)(9)

Flow-down and lower-tier plan requirement

(d)(10)

Reporting and cooperation assurances

(d)(11)

Recordkeeping description

(d)(12)

Good-faith effort on concerns used in the proposal

(d)(13)

Written explanation if (d)(12) is not met

(d)(14)

No bar on subcontractor contact with the CO

(d)(15)

Timely payment of small business subcontractors

Status computed by rule Referred for Director judgment

Some agencies require more. VA adds four elements through VAAR 852.219-70, so a VA review evaluates eighteen rather than fifteen — cited to VAAR, not to the FAR.

The distinction that matters

Absent is a deficiency. Thin is a judgment call.

A plan can address every element and still fall short. Treating those two situations identically is what makes automated compliance tools useless to a reviewer — everything becomes a finding, or nothing does. Below is an actual review of a plan where all fifteen elements are present.

(d)(1)Goals stated in dollars and percentages for all six categoriesSatisfied

(d)(3)Types identified for small business only, not for the other five categoriesDeficient

(d)(4)Asserts a basis in the incumbent supplier base; describes no methodFor judgment

(d)(6)Indirect costs excluded — allocation method not requiredSatisfied

(d)(10)Assurances (i), (ii), (iv), (v) present; (iii), (vi), (vii) absentDeficient

(d)(11)Cites a records policy without describing any required record typeDeficient

Three deficiencies, several judgment items, and a reason attached to each. Run the same plan again tomorrow and the deficiencies are identical — because a rule decides them, not a model.

Authority

Built on the text your agency actually follows

The Revolutionary FAR Overhaul rewrote Part 19, and agencies adopted the deviated text through their own class deviations rather than through a single rule. They did not all adopt on the same date, and some supplement it with their own regulation. A system built on the codified FAR is citing requirements that no longer govern.

HHS FAR Class Deviation 2026-01, Amendment 2 — 24 April 2026, which rescinded and superseded the original and Amendment 1 15 elements

VA Class deviation of 19 November 2025, plus VAAR 852.219-70 and the Veterans First Contracting Program at 38 U.S.C. 8127–8128 18 elements

Two agencies. Two governing instruments adopted five months apart. One of them adding four requirements the other does not have. Deviation-awareness is not a claim about this system — it is the difference between those two rows.

Cited to the instrument

Findings cite the RFO model deviation text and the class deviation that adopts it, by number and date. The configuration is versioned, so a determination signed today stays traceable to the exact text it was judged against.

Recorded on every memorandum

Agency supplements applied

Where an agency adds requirements through its own regulation, those are evaluated alongside the FAR elements and cited to that regulation — never to the FAR.

VAAR 852.219-70 · VA Form 0896A · SBA VetCert

Superseded references caught

Reporting moved to SAM.gov and agency regulations are still catching up. A plan naming a retired system is flagged as correctable — not treated as compliant, and not treated as a failure.

eSRS · VA Vendor Information Pages

Alternates and plan types

A master plan is not required to contain goals. Under Alternate III the Individual Subcontract Report goes on SF 294 rather than through SPR. Both are applied as supplied — a system that misses them generates findings that are simply wrong.

Alternates I–IV · individual, master, commercial

What the system declares about itself

Every determination states what the analysis assumed.

Some things cannot be verified from a submitted document. Where that is true, the memorandum says so on its face — before the determination block, where the signer will read it.

A1 — Part 19 currency (unconfirmed — confirm before relying on affected findings)
What was assumed, what changes if it is wrong, which element is affected, and how to resolve it — each stated in full on the memorandum itself.

A determination resting on an unverified premise should say so where the person signing it will see it, not in a configuration file nobody opens. Most systems of this kind cannot answer the question “what did you assume?” at all.

Delivery

Three parties, one accountable structure

Methodology, platform, and federal infrastructure are held by parties that each answer for their own part.

Methodology

JCG Consulting Group

The PTOD-OS organizational intelligence framework and the analytic approach behind the review.

Platform

MindStreams Technology

Engineering, the evaluation engine, and the determination record — adapted from a regulated-industry review system already in production.

Federal infrastructure

H4 Enterprises

Contracting entity, registered in SAM, with FedRAMP-authorized hosting. Contractor-submitted material is processed inside that authorized environment.

Next step

See it review a real plan

A thirty-minute walkthrough: a compliant plan clearing with no findings, a deficient one producing a full deficiency record, and the case that matters — a plan where every element is present and three are substantively absent.

Request a walkthrough Sign in to the system

Access to the review system is issued to named individuals. Credentials are required at sign-in.

PTOD-OS Federal performs structured evaluation and prepares determination records. It does not accept, reject, or return subcontracting plans, and it makes no determination. Every determination is made and signed by the cognizant official. Capability demonstrated against synthetic subcontracting plans; agency deployment is scoped and authorized on a per-engagement basis.